This April, CMS published its hospital inpatient prospective payment system (IPPS) proposed rule for fiscal year 2018. However, out of the 1,832-page tentative rule, people have been mostly focused on a 13-page section within it.

The section in question would require accrediting organizations (AO) to make survey reports or plans of corrections (PoC) publicly available online within 90 days of the information becoming available to the healthcare organization. The online reports would include details of all triennial, full, follow-up, initial, recertification, focused, and complaint surveys, whether they are performed on-site or off-site. This would apply to all AOs, including The Joint Commission, DNV, HFAP, CIHQ, and others. The details of the proposal were further clarified in a CMS survey-and-certification memo, S&C 17-24-ALL. (For related links, see Resources at the end of this article.)

“Access to survey reports and PoCs will enable health care consumers, in addition to Medicare beneficiaries, to make a more informed decision regarding where to receive health care thus encouraging healthcare providers to improve the quality of care and services they provide,” CMS wrote in the proposal memo.

However, there are concerns that this move creates an uneven playing field in hospital quality and oversight. It’s also argued that the public might have trouble deciphering the contents of accreditation reports, leading to more confusion.
What The Joint Commission says

The Joint Commission responded to CMS’ proposed rule by saying it’s opposed to sharing private survey reports. In an open letter to CMS, The Joint Commission President and CEO Mark R. Chassin, MD, FACP, MPP, MPH, wrote that while the accreditor is a strong supporter of transparency, it believes revealing all accreditation survey reports to the public is a bad idea.

The crux of the issue is that the contents of those survey reports are meant as tools for hospitals to improve, he says. It’s not the same as healthcare quality data, a distinction that might be lost on the public.

“As an organization whose mission is to support quality improvement and patient safety and inspire excellence, we believe the proposal will have significant detrimental consequences on our nation’s ability to continually improve the delivery of healthcare services,” Chassin wrote. “To be clear, this opposition is not one against transparency, but one of creating the right balance between useful, publicly available information and improving the quality and safety of healthcare.”

Some of The Joint Commission’s concerns are:

• It’ll be harder to get AOs and healthcare organizations to collaborate on patient safety and continuous quality improvement. Having AOs release collected information would make providers less candid about their weaknesses and create an adverse dynamic that will ultimately result in increased patient harm and lower quality.
• The proposal will stunt AOs’ efforts to create new standards or raise compliance standards for existing requirements.
• Healthcare organizations will be incentivized to use AOs that report on the least number of Medicare-comparable standards. This will spur a race to the bottom on quality. It might also increase the number of non-accredited facilities that’ll be surveyed at taxpayer expense and with fewer oversight visits.
• The proposal will diminish the value of accreditation as a way to motivate healthcare organizations to excel.
• The proposal will increase costs for AOs and healthcare organizations.
What experts say

Elizabeth Di Giacomo-Geffers, RN, MPH, CSHA, a former Joint Commission field representative and current president of DiGiacomo-Geffers and Associates, says, “At this time I cannot support CMS’ position and feel it will have a negative effect around the world for all the healthcare organizations, accrediting organizations, and the patient population served. I would recommend that CMS and all the accrediting agencies meet to review, discuss, and evaluate the potential outcomes.”

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